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Judgment
This assessee’s appeal for assessment year 2019-20, arises against the Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre, [in short, the “Ld. CIT(A)/NFAC”], Delhi’s order dated 06.03.2026 having DIN & Order No. ITBA/NFAC/S/250/2025-26/1086955785(1), involving proceedings under section 147 of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’).
Heard both the parties. Case file perused.
Coming to the assessee’s first and foremost substantive ground, it is evident, at the outset that there is hardly any need for tribunal to delve with the relevant factual matrix at length in so far as the correctness of both the learned lower authorities’ action, adding the loan transaction in issue of Rs. 15 lakhs u/s 69A of the act, in the assessment order as upheld in the lower appellate discussion is concerned. This is for the precise reason that for the impugned assessment order in A.Y. 2019-20, the assessee had submitted his explanation that the same was received way back on 16.01.2013 going by his bank statement forming part of the records. This clinching factual position has gone unrebutted from the Revenue’s side. I find merit in the assessee’s case and delete the impugned addition of Rs. 15 lakhs in very terms.
In the result, the assessee's appeal is allowed.